Vol. 41 No. 3 - Summer 2022

Taxation

Looking to the Future

Wells Hall

Having the opportunity to Chair the ABA Tax Section would be the highlight of any tax lawyer’s career. Certainly that is the case for this farm boy from North Carolina. Thank you for the opportunity to serve in this capacity for the 2022-23 year. ...

Taxation

Interview with Keith Fogg

Jeremiah Coder

T. Keith Fogg retired at the end of June 2022 as the director of the Federal Tax Clinic at the Harvard Legal Services Center, where he was clinical professor of law since 2017. He was interviewed by ATT editor Jeremiah Coder.

Taxation

Counterpoint: The IRS’s First-Time Abatement Policy . . . Even Harsher Than You Realized

Melissa L. Wiley

This article explores the IRS’s first-time abatement policy that may be overlooked, including how the policy applies to some international information returns, and how it applies when the taxpayer also has reasonable cause for the penalized failure.

Taxation

Debt-Financed Distributions Are Still the Name of the Game in Subchapter K

Sue (Suyoung) Moon

Partnership distributions have been a key issue for the IRS in recent years. In particular, the disguised sale rules under section 707 of the Internal Revenue Code and the debt-financed distribution exception under the Treasury Regulations have...

Taxation

Supreme Court Grants Certiorari in Bittner

Stephen J. Dunn

The Bank Secrecy Act authorizes a $10,000 penalty for each non-willful violation. In Bittner, the Fifth Circuit held that each account omitted from a timely-filed FBAR is a separate "violation." The Supreme Court has granted certiorari in Bittner.

Taxation

Pro Bono as a Business Development Tool

Andrew R. Roberson

Attorneys do pro bono work for a variety of reasons. Most common is that you enjoy helping those who could not otherwise afford to hire any attorney. One benefit that I never imagined when I first started was on the business development side.

Taxation

A Primer on State and Local Taxation of Utility-Scale Wind and Solar Projects

Jennifer R. Pusch

This article provides background on the components that make up wind and solar projects, summarizes commonly applicable state and local taxes, and concludes with a brief discussion of why developers should care about state and local taxation.

Taxation

Save the Date: 22nd Annual Law Student Tax Challenge (2022-2023)

An alternative to traditional moot court competitions, the Law Student Tax Challenge asks two-person teams of students to solve a cutting-edge and complex business problem that might arise in everyday tax practice.

Taxation

Season 4 Update

New Season 4 episodes include interviews with James Creech, Michael Desmond, Samantha Galvin, Janice Shih, Jonathan Grossberg, Bob Wunderle, and Marie Milnes-Vasquez.

Taxation

Tax Law and Politics

Robert S. Steinberg

To the tune of Hooray for Hollywood by Richard A. Whiting and Johnny Mercer (1937), sung by Nancy Sinatra or the Village Pops Chorus (2017) or performed by the Boston Pops.

Taxation

New Edition of Multijurisdictional Admission to Practice Requirements for SALT Lawyers

The Tax Section has published the 2022 edition of the Guide to Multijurisdictional Admission to Practice Requirements for State and Local Tax Lawyers. A project of the State and Local Taxes (SALT) Committee, the guide synthesizes the requirements...

Taxation

Statement on IRS Funding in Inflation Reduction Act

The Section has consistently supported the adequate funding of the Internal Revenue Service (the “Service”) and applauds Congress and the President for providing increased funding for the Service over the next 10 years in Part 3 of the Inflation...

Taxation

Identifying Future Leaders: A Message from the Chair of the Nominating Committee

The Nominating Committee of the ABA Tax Section seeks nominations for new members of the leadership Council to serve from August 2023 to August 2024. The leadership Council is responsible for the financial and programmatic health of the Section.

Taxation

2022-2025 Loretta Collins Argrett Fellows

The American Bar Association Section of Taxation is proud to announce the 2022-2025 Loretta Collins Argrett Fellows. The Fellowship seeks to create a more accessible and equitable pipeline into the Section and the tax bar.

Taxation

Virtual 2022 Fall Tax Exempt Organizations Symposium

The Exempt Organizations Committee will present its Fall programming at this specialized full-day virtual symposium rather than at the in-person Fall Tax Meeting. With four plenary panels addressing topics of general interest...

Taxation

Government Submissions Boxscore

Government submissions are a key component of the Section's government relations activities. The full archive is available to the public on our website.

Taxation

Accepting Applications for the 2023-2025 Christine A. Brunswick Public Service Fellowship

The American Bar Association Section of Taxation is pleased to announce that it is now accepting applications for its Christine A. Brunswick Public Service Fellowship program class of 2023-2025.

Taxation

Call for Applications: Diversity and Inclusion Scholarships to 2022 Fall Tax Meeting

The Tax Section is now accepting applications for the Diversity and Inclusion Scholarships, designed to encourage members of diverse backgrounds or with a recognized commitment to diversity and inclusion to attend and participate in the...

Taxation

Get Social

Stay up-to-date on the latest tax news and Section updates and events. Follow us on Twitter, LinkedIn, or Facebook. Share our recent posts with your networks and tag us in your updates!

Taxation

Hybrid 2022 May Tax Meeting Materials Now Available

Did you know that ABA Section of Taxation members have access to thousands of pages of cutting-edge committee program materials presented at Section meetings?

Taxation

The Tax Lawyer—Summer 2022 Issue Now Available

The Tax Lawyer, the nation's premier tax law journal, is published quarterly as a service to members of the ABA Section of Taxation.

Taxation

The Practical Tax Lawyer—September 2022 Issue Now Available

Produced in cooperation with the ABA Section of Taxation and published by ALI-CLE, The Practical Tax Lawyer offers concise, practice-oriented articles to assist lawyers with all aspects of tax law.

Taxation

Help Create a More Just, Equitable, Inclusive, and Diverse Tax Section with a Contribution to the JDEI Fund

Donate to the recently launched JDEI Endowment Fund which provides funding for the Loretta Collins Argrett Fellowships and Tax Section efforts to create a more diverse tax bar. ...

Taxation

Support the Section’s Public Service Efforts with a Contribution to the TAPS Endowment

Through the Tax Assistance Public Service (TAPS) endowment fund, the Section of Taxation seeks to provide stable, long-term funding for its tax-related public service programs.

Taxation

Get Involved in ATT

ABA Tax Times (ATT) is looking for volunteers to join its ranks as associate editors to assist in writing and acquiring articles for publication.

Taxation

Section CLE Products

Listen at your convenience to high-quality tax law CLE on a variety of tax topics. Here are the latest.

Taxation

Sponsorship Opportunities

Opportunities are available to enhance your visibility, grow your network, and expand your reach at ABA Section of Taxation meetings.

Taxation

Renew Your Tax Section Membership

ABA Section of Taxation

Have you renewed your ABA Section of Taxation Membership? Don’t miss out on practice-specific content. Renew today to maintain access to resources like this and more.

Taxation

Hybrid 2022 May Tax Meeting and 14th Annual U.S. and Latin America Tax Practice Trends Conference Sponsors

ABA Section of Taxation

Thank You To Our Hybrid 2022 May Tax Meeting and 14th Annual U.S. and Latin America Tax Practice Trends Conference Sponsors!

Taxation

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ABA Section of Taxation

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